Armstrong 1: Correspondence

CONTOS 8c BUNCH

LAWYERS

July 16, 1986

5055 TOPANGA CANYON BOULETVARD
SUITE AOO

WOODLAND HILLS. CALIFORNIA 91367-A69A
(bis) 716-9AOO

MANUFACTURERS BANK BUILDING
1201 DOVE STREET
PENTHOUSE

NEWPORT BEACH. CALIFORNIA 92660-28A1
(71A) 752-OA80

REPLY TO: Woodlaud Hllls

The Honorable Paul G. Breckenridge, Jr.

SUPERIOR COURT OF CALIFORNIA
111 North Hill Street, Dept. 57
Los Angeles, California 90012

Re: Gerald Armstrong vs. Church of Scientology

of California; LASC Case No. C420153(severed action)

Dear Judge Breckenridge:

On June 26, 1986, the Court ordered that the three boxes of
Mr. Armstrong’s Pre-Clear Folders were to be made available
for inspection and/or copying at a place convenient to the
County Clerk, commencing at 9:00 A.M. on July 15, 1986.

In an attempt to comply with the Order, I spoke to Cynthia
Collins, a representative of the County Clerk's Office on
July 15, 1986. Ms. Collins advised me that copies of the
Pre-Clear Folders could only be made by representatives of
the County Clerk at $.57/page. Ms. Collins further advised
me that the Court had confirmed the same in a telephone con¬
versation and that a Minute Order would be issued.

Although I had made arrangements for an outside copying
service to copy the Pre-Clear Folders at a time and place
convenient to the Court Clerk, Ms. Collins advised me that
this procedure was not possible since the outside copying
machine would be using County electricity. I have made
attempts to find a service that does not utilize electricity,
but have been unsuccessful.

My client, Mr. Armstrong, desires a full copy of the Pre-
Clear Folders, thereby necessitating copies of the three
boxes of materials. At $.57/page this could cost Mr. Armstrong
thousands of dollars which he does.not have.

I am thus requesting, on behalf of Mr. Armstrong, that some
other arrangements be made for the inspection and copying of
the Pre-Clear Folders. If counsel for the Church of Scientology
of California have no objections, I suggest any one of the

The Honorable Paul G. Breckenridge, Jr.
SUPERIOR COURT OF CALIFORNIA
July 16, 1986 - Page Two

following procedures be followed:

(1) The three Beakins' boxes could be picked up by
a representative of my office, in my presence
and in the presence of a representative of the
Church of Scientology of California, and delivered
to an outside agency for copying. I and a repre¬
sentative of the Church of Scientology of California
could observe the copying process and then return
the three boxes to the Court for safekeeping; or

(2) A representative of my office could pick up the
three Beakins' boxes from the Court in the
presence of a representative from the Church of
Scientology of California and bring the boxes back
to my office. There, in the presence of a repre¬
sentative of the Church of Scientology of
California, the documents could be copied on our
machine and then immediately returned to the Court
for safekeeping.

Mr. Armstrong has been waiting a very long time to obtain copies
of the Pre-Clear Folders. He thus requests that the Court
provide a more equitable means for him to obtain the same.

Very truly yours,

CONTOS & BUNCH

JULIA DRAGOJEVIC
JD: pr

cc; Gerald Armstrong

Donald C. Randolph, Esq.
John G. Peterson, Esq.